SITE INFORMATION AND CORRESPONDENCE

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low San Joaquin County DIRECTOR P4 Donna Environmental Health Department ASSISTANNTT DHeraIRECTOR REHS RECTOR 600 East Main Street Laurie Cotulla, REHS W. Stockton, California 95202-3029 PROGRAM COORDINATORS Carl Borgman,REHS c :. p Mike Huggins, REHS, RDI Website: www.sjgov.org/ehd Margaret Lagorio,REHS Phone: (209) 468-3420 Robert McClellon,REHS Fax: (209) 464-0138 Jeff Carruesco,REHS,RDI Kasey Foley, REHS SEP 1 0 2007 SUSAN OAKDEN VICTORIO ARANDA RICHARD OAKDEN TRUST 5487 E MARSH STREET 1200 WATT AVENUE STOCKTON CA 95215 SACRAMENTO CA 95864 RE: Former Electro Delta included in the WP 821 S. Wilson Way Stockton, CA San Joaquin County Environmental Health Department (EHD) has reviewed "Quarterly Report — First Quarter 2007" dated May 9, 2007, and "Additional Site Assessment Work Plan" (WP) dated May 4, 2007, prepared by Advanced GeoEnviron mental, Inc. (AGE) for the above referenced site. In a telephone conversation on June 6, 2007, EHD discussed with AGE that the determination, included in the WP, that excavation of the hydrocarbon impacted soil was not feasible because it was next to the sidewalk and building was not acceptable. Also, stating that the impacted soil and groundwater contamination would require in-situ remediation, without citing any viable in-situ methods is not acceptable. The geologic cross-section dated November 15, 2005, prepared by AGE, shows silty clay and clayey silt from surface to 40 feet below surface in the area where the underground storage tank (UST) was located. From the soil sample results and site information that have been gathered to date it appears that the soil contamination is limited to the area beneath the former UST. AGE did not provide any specific in-situ remedial alternative to clean up the contaminated soil and EHD is not aware of any feasible cost effective remedial alternative to clean up clayey silt and silty clay other than excavation. There are methods to excavate the soil and protect the building and sidewalk such as using shoring and/or bucket auger drilling that should be evaluated. Since a complete evaluation for remediation of the contaminated soil was not provided and all the monitoring wells proposed in the work plan are close to the location of the former UST, the WP is not approved. A complete evaluation of cost effective viable remedial alternatives for the soil is to be submitted to EHD by November 1, 2007. In order to demonstrate that an alternative proposed to remediate the soil (other than excavation) at this site is viable, please provide site addresses where the alternative has been used successfully with geologic cross-sections of the site to show that the soil type remediated was the same as the soil type at this site, and the oversight agency contact information.